Select Committee on Environmental Audit Minutes of Evidence


Supplementary Memorandum by the Ministry of Agriculture, Fisheries and Food

REPONSES TO FURTHER WRITTEN QUESTIONS FROM THE COMMITTEE

HOUSEKEEPING STRATEGY

16. The targets you mentioned in your memorandum, for energy saving of 20 per cent and for paper recycling, are not set down in your Strategy or the Action Plan also supplied to the Committee. Are they set out in some other document? Do you have any other commitments to specific green housekeeping targets?

  The 20 per cent. target for energy saving reflects the Government-wide target for reduction in energy consumption by March 2000 (as promoted by the then Department of the Environment in 1996) and is referred to in the Ministry's Annual Departmental Report.

  The target for paper recycling was set after the Ministry's Strategy and Action Plans were written and was in any case of local rather than MAFF-wide interest. The target represented a simple aim of around half a tonne a week at our London HQ buildings and was decided upon locally. The whole scheme was given extensive internal publicity to encourage participation including a series of presentations to staff.

  Other targets in place or under consideration are:

      —  An increase in the paper recycling target for London HQ to 40 tonnes.

      —  To have green transport plans in place at headquarters offices by March 1999.

      —  To meet the standards set down in the Strategic Guidance for London Planning Authorities for car parking at Ministry sites in greater London by the end of the year 2000. This requires no more than 1 space per 1,000-1,500 sq m ground floor area.

      —  To seek BREEAM certification at the highest possible level for all new buildings and major refurbishments.

ENVIRONMENTAL MANAGEMENT SYSTEMS

17. What was the scope of the consultants review which advised MAFF on whether to introduce Environmental Management Systems?

  The consultants were asked to advise the Ministry on whether or not it was feasible or desirable to implement a formal Environmental Management System. They were also asked whether or not it would be appropriate to implement an Environmental Management System through meeting the requirements of BS 7750 or whether it would be more appropriate to use a different approach. In the process they were asked to give the costs and benefits of each option, including the staffing implications and benefits. As part of the exercise, they had to visit sample sites consisting of an office in central London, a large veterinary laboratory and a farm. They then extrapolated the results across the whole of the MAFF estate.

18. What costs contributed to the total estimate of £0.5 million for the set-up of environmental management systems and £0.5 million for running costs. What benefits were appraised?

  The overwhelming majority of the costs consisted of staff costs. For the set up of an environmental management system they included: time for a preparatory environmental review of the sites concerned and consideration of the results, the development and approval of policy, reviewing of job descriptions, assessment of training needs and development of record keeping, setting up procedures with contractors, setting up registers for environmental effects and relevant legislation, the setting of objectives and targets, setting up programmes, collating documents, writing procedures for operational control and developing plans and procedures.

  The assessment of running costs included: on-going awareness training for staff, monitoring of contractors, environmental effects and legislation, the management and implementation of programmes, on-going review and development of management manual, monitoring data requirements for management records, implementation of audits and an annual review of strategy.

19. To what extent were these costs for systems which you recognised as valuable irrespective of the decision whether to introduce an accredited environmental management system? Were there any changes introduced as a result of the consultants' work?

  The potential benefits of an EMS were identified as the avoidance of costs arising from failure to comply with regulations or failures of control; cost savings through, for example, reductions in water use and waste disposal; market benefits and public relations benefits.

  We recognise that there are aspects of an EMS which are valuable: monitoring, raising staff awareness and site auditing are all worthwhile but the conclusion was that a full EMS was not justifiable. But it was as a direct result of the study that the audit of laboratories referred in the response to Q.11 below was commissioned; and we would hope to institute improvements in other aspects of the Ministry's environmental management, resources permitting.

20. Is the contract for the environmental audits of 24 laboratory sites expected to be a one-off exercise?

  The need for any further audits for the 24 laboratory sites (or any other sites) will depend upon the results of the exercise now underway. If this reveals that local management systems are adequately controlling all environmental outputs then formal consultancy audits are unlikely to be repeated in the near future. If the audits reveal any serious failing these will have to be addressed urgently and further audits might then be undertaken.

ESTATE

21. Will the audits of 24 laboratory sites involve assessment of the level of contamination of the sites?

  The laboratory audits are expected to identify any apparent contamination of the sites or adjacent water sources. Although not the primary reason for the audits (which is to evaluate compliance with legislation and good practice), these aspects have been specifically discussed with the Consultants. If any problems should come to light, further detailed studies would be considered.

22. Will MAFF audit the remainder of the sites in its estate to identify any which are contaminated and require remedial actions?

  Any sites which are due for disposal are first audited for evidence of contamination. Otherwise we would not consider other sites for auditing unless we suspected that there was contamination arising from current practices (bearing in mind that the majority of our sites are offices with little scope for causing contamination). We have no reason to suppose that there are problems at any Ministry sites where contamination has not already been identified, apart from a redundant buffer depot in N. Wales where we are taking remedial action.

PROCUREMENT

23. Has the Department audited actual procurement practice to confirm whether purchases are being made in accordance with the policy requirements?

  To date, the Department has not audited actual procurement practice to confirm whether purchases are being made in accordance with the (Green Operations) policy requirements. We believe that we do not purchase goods containing CFCs and substances subject to the Montreal Protocol. We buy recyclable products where their technical performance is demonstrably adequate. Actual procurement practice is audited regularly with regard to seeking value for money in accordance with the Government's policy on procurement. Value for money is defined as the optimum combination of whole life cost and quality to meet the user's requirements.

  There remains widespread uncertainty on the technical issues underpinning Green procurement: particularly as to what is and what is not green and how it can be measured. In addition, there is the question of how far up the supply chain it is feasible to go and what influence can be brought to bear well up the chain. The Department is limited by its obligation to comply with the EU procurement regulations in the extent to which it may have recourse to environmental considerations in the tendering process. To the extent that specifications are restricted by those rules, the enforcement of any environmental conditions in the subsequent management of the contract is also restricted.

  It is important to note that MAFF makes every reasonable effort to ensure it discharges its statutory obligations. Equally, suppliers cannot contract out of statutory obligations. We are aware of the existence of formal standards for environmental management systems which can assure purchasers that suppliers are operating to control their environmental impacts. These schemes are voluntary and it is against current Government procurement policy to require suppliers to comply with them as a condition of selection on award of contract. However, a number of our leading suppliers have already obtained BS EN 14001 certification, and others are in the process of obtaining it. In addition, we know that other suppliers with whom the Ministry deals are giving serious consideration to environmental factors in their supply chain(s).

  Accordingly, and noting our obligation to comply with Government procurement policy and our specific responsibility to treat all suppliers equally, we intend in 1998 to:

    (b)  host our own Departmental procurement conference at which environmental considerations in procurement will be discussed (involving a number of key Departmental suppliers); and

    (c)  review our disposal procedures for IT equipment.

  In addition, and subject to the same provisos, above, we propose to have technical discussions with a range of MAFF's leading suppliers on their own environmental strategies, and send selected procurement staff on supplier assessment courses having a focus, in part, on environmental auditing of suppliers.

  MAFF accepts that environmentally friendly products and services can cost less but believes equally that specifications of particular environmental requirements can result not just in serious supply market distortion but in diminished technical performance, and higher costs which will not be offset by savings over the longer term.

ENERGY EFFICIENCY

24. How did MAFF achieve such a significant jump in the rate of improvement in energy efficiency (-13 per cent in 1996-97 as opposed to -1 per cent over the previous five years) in one year? Set against this level of improvement is a target of 20 per cent improvement by 2000 sufficiently challenging?

  This significant improvement is due to a number of factors. The DETR agreed with us that a more realistic picture of the main estate and a closer comparison with other Departments would be achieved in 1996-97 by transferring the certain "non office" buildings from the main estate category to the laboratories category. These buildings comprised the fisheries laboratories (CEFAS) and the veterinary investigation centres (VICs) which are higher users of energy than normal office buildings. Continued commitment to various energy schemes—low energy lighting, movement detectors, more efficient heating controls, building insulation, better metering and an energy staff awareness programme have also contributed to improved performance.

  We consider the 20 per cent target for the year 2000 as extremely challenging. Further improvements are more difficult to find as energy consumption falls in response to earlier initiatives.

25. Does the Department have a policy of purchasing energy efficient IT equipment? If so, How much has this contributed to the Department's energy efficiency performance?

  The Department continually evaluates new desktop IT equipment. That evaluation includes assessment of environmental issues, including power consumption. PCs on the Department's list of approved IT products have a feature, whose use is encouraged, which puts them into a low power state when they are inactive for a period. Other IT equipment such as computer servers are also assessed for any requirements for their operating environments (e.g. cooling, air conditioning) and the effect on running costs. The Department also seeks to re-use its surplus IT equipment to cut down on the environmental impact arising from new manufacture.

  There is no central inventory of the numbers of each type and model of IT equipment in use within the Department, however it is estimated that equipment such as printers, scanners, main frames and servers represent approximately 88 per cent of the total IT energy consumption and PCs about 12 per cent. Power saving PCs probably contribute about 1 per cent of the Department's energy efficiency performance.

WASTE

26. What is the basis for MAFF's reservations on setting targets for waste minimisation? What measures have been undertaken? Do you maintain records of improvement despite remaining uncommitted to a particular target?

  Whilst the Ministry fully recognises the merits of minimising waste, it has only limited resources it can devote to the subject and is inclined to the view that setting targets and measuring waste volumes is not necessarily the most productive way forward on its own greening operations.

  There can be many factors which can impact on the quantities of waste produced at any given site. There can be internal reorganisations of which MAFF has had continual experience over the last few years. For example, the Ministry's HQ recently underwent substantial re-organisation when its Ministers, Secretariat and Press Branch moved between buildings, and considerable change was required to bring together the staff who will be transferred to the Food Standards Agency. Changes inevitably generate an upsurge in waste when staff move offices. The end result can be the concentration of more staff into less space (as the Ministry strives to become more space-efficient) so that on an ongoing basis a building might produce more waste as more business is conducted from that site.

  Efforts to increase the productivity of staff can impact on the waste that they produce; so too can computerisation: and changes in staff responsibilities as new schemes and policies come to be dealt with. It would be very difficult to assess the impact of these sorts of factors on any targets that might be set to ensure a level playing field. To attempt to do so at all of the Ministry's 240 sites would be beyond our resources and seems unlikely to produce anything meaningful which would be likely to influence people's behaviour. It might be possible to set targets at a few of our smaller and relatively more stable locations. Otherwise, it seems more productive to concentrate on publicity initiatives to encourage waste minimisation. This has been the course adopted by the Ministry (with training, talks and exhibitions for example) rather than measuring waste streams.

  Finally, we are faced with the practicality of measuring waste. Most waste from large sites is taken away in skips or large wheeled bins. These are not weighed and it would probably cost a lot to have them weighed, even if it were practical to do so. We could count the numbers being taken away, but we are not sure what this would achieve given that the bulking of the waste in the bins can vary greatly. And any suggestion that the different types of waste should be separated before disposal would be very expensive indeed.

EXECUTIVE AGENCIES AND NDPBS

27. Which MAFF Agencies have direct environmental impacts such as emissions or significant use of non-renewable resources?

  The main MAFF Agencies which have the potential to cause direct environmental impacts include the Veterinary Laboratory Agency (VLA) the Central Science Laboratory (CSL) and the Centre for Environment, Fisheries and Aquaculture Science (CEFAS). Most emissions are subject to legislative requirements which regulate their impact on the environment.

  In the past, the Central Veterinary Laboratory (part of the Veterinary Laboratories Agency) was a significant user of oil to power its central boiler plant. In 1995 the boilers became dual fired and natural gas is now the fuel of choice. In the same year, a new incineration plant came on line which has a waste heat boiler. During the summer months the waste heat provides all of the site's heating, hot water and steam.

  The Central Science Laboratory produces both air-borne and water-borne emissions in small amounts. Water discharges are subject to approval by the Environment Agency and Yorkshire Water. Air-borne emissions include small amounts of solvents and, whilst no licence is required. CSL employees follow best practice to minimise such emissions. CSL's only significant use of non-renewable resources arises from energy usage. Energy efficiency was a prime consideration in the design of the new laboratory at York. In addition, MAFF commissioned consultants to produce an environmental impact study when collocation at York was being considered.

  The Centre for Environment, Fisheries and Aquaculture Science includes a number of laboratory sites and research vessels. There are discharges of water used in experimental studies, venting of fume cupboards to the atmosphere, and the normal operating effects of ocean-going ships. All discharges comply with statutory requirements.

28. Has the Department required its Agencies to identify their environmental impacts and to set policies to address them?

  Agencies have signed up the MAFF Green Housekeeping Strategy. Specifically, in 1993 when there were plans to expand the Central Veterinary Laboratory site, consultants were commissioned to carry out an independent Environmental Impact Assessment. The report also covered the environmental impacts of existing activities on such areas as landscape, ecology, water, air, noise, heritage and archaeology.

  The CSL emissions were largely identified in the environmental impact study referred to in the answer to Q27. As regards CEFAS, the Agency operates to a policy of minimising impacts as appropriate to each activity. Because much of the Agency's work relates to environmental protection (conservation of fish stocks, prevention of pollution etc.) there is a natural awareness and sense of responsibility in the way that the work is carried out.

29. Has the Department considered setting relevant Agencies a target for emissions and publicly reporting compliance?

  The Department has not considered setting its Agencies a target for emissions and publicly reporting compliance. However, returns are made as required under consents for discharges and for the monitoring of gases from incinerators. Results reported are then in the public domain.

30. How have the NDPBs responded to your invitation to take up the question of greening their operations and addressing their energy efficiency?

  The impact which many of our NDPBs can have on energy efficiency and greening measures generally is extremely limited. Some are very small organisations and occupy only a few rooms in offices run by other organisations. They do not contribute to the energy efficiency campaign as such with its 20 per cent. target. However, in the past we have had positive responses from many of them on energy efficiency and where it was appropriate some signed up to the Corporate Commitment to Energy Saving. Kew Gardens for example won a BETA award for energy efficiency. On greening matters generally, we have also had some positive reactions from the Wine Standards Board, the Covent Garden Market Authority and the Meat and Livestock Commission. For the latter in particular their initiatives included paper recycling, the removal of halon fire extinguishers and the control of vehicle emissions. We will re-approach all our NDPBs as we develop our policy.


 
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